Introduction

Greenetro Infrastructure & Development Limited and its affiliates (hereinafter called “Greenetro”/ “We”/ “Our”) treats personal information of users (“Users”/ “You”/ “Your”) of the Greenetro Website “www.greenetro.com” and its other digital platforms (hereinafter called the “Site”) as private and confidential.

This Privacy Policy (“Policy”) describes what personal information Greenetro collects, what Greenetro does with it, how Greenetro protects it and how Greenetro maintains information collected from Users of the Site. We are a Data Controller – meaning that we determine the purposes for and manner in which Personal Data is processed or is to be processed.

This Policy applies to usage of the Site as well as information contained on the Site, particularly, information related to products and services offered by Greenetro.

Greenetro is committed to ensuring that Your privacy is protected. Should We ask You to provide certain information by which You can be identified when using this Website, then You can be assured that it will only be used in accordance with this Policy.

What we collect

We may collect the following Personal Data:

• Personal identification information – We collect and use information about You to administer Our business. Information collected shall include
• Your contact information such as name, contact address, email addresses, gender, and telephone numbers and details of next of kin;
• Demographic information;
• Occupation, career history, professional background and other CV related information;
• International and national passport, driving license or any other form of proof of identification;
• Transactional data, including financial details, your photograph; and
• And any other information We may deem necessary and which may be determined by extant Nigerian laws and regulations.

We may collect personal identification information from you in a variety of ways, including, but not limited to, when you visit our Site, register on the Site, make payments for our products and services, subscribe to Our newsletter, respond to a survey, or fill out a form, and in connection features or resources made available on our Site.

• Non-personal identification information – This is information received whenever You interact with Our Site. Non-personal identification information may include:
• Unique IDs such as your mobile device identifier or cookie ID on your browser;
• IP address and information that maybe derived from IP address, such as geographic location; and
• Information about a device you use, such as browser, device type, operating system and the internet service providers utilized.

Other information relevant to customer surveys and/or offers

Why we collect your Personal Data

All Personal Data which we collect, and process is justified by lawful processing on the legitimate basis that:

• You have given consent to the processing;
• Processing is necessary for the performance of a contract to which you are a party or take steps to enter into a contract;
• Processing is necessary for compliance with a legal and regulatory obligations to which we are subject;
• Processing is necessary in order to protect your vital interests or another natural person; and
• Processing is necessary for the performance of a task carried out in the public interest.

What we do with the information we gather?

We require this information to understand your needs, and provide you with better service, particularly with regard to the following:

• Internal record keeping;
• To respond to your enquiries about Greenetro;
• To improve our products and services;
• To improve customer service delivery;
• To send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided;
• To contact you occasionally for market research purposes. We may contact you by email, phone, fax or mail;
• To deliver technical and functional management on our site;
• To provide specific services in accordance with an agreement you are entering, or have entered into with us;
• To manage the security of our sites, networks and systems;
• To comply with applicable laws and regulations and to operate our business;
• To run a promotion, contest, survey or other site features; and
• To improve our Site through feedback you provide on our products and services.

Greenetro will not share with other parties, information which you may provide when using the Site, except to the extent necessary to provide services to you, further, to obtaining your consent.

With your express consent, we will share your personal data among Our affiliates, only to the extent of your permission, and which is necessary to provide services to you. In this case, your right to withdraw consent shall be exercisable at all times.

Marketing

We may wish to share with you, information about our products and services which we think you may be interested including those of our subsidiaries. If you have agreed to receive marketing materials, you can always opt out at a later date. You reserve the right at any time and at no cost to you, to stop us from contacting you for marketing purposes or giving your data to our subsidiaries

How we collect Personal Data

We collect information about you and any other party whose details you provide to us when you:

• Provide feedback on our products and services to improve our Site;
• Complete online forms;
• Take part in surveys;
• Interact with us using our social media platforms;
• Download information such as publications or participate in any other interactive areas that appear on our website or portals;
• Contact us offline, for example by telephone, SMS, email, post or any other means of communication;
• Access and use any of our websites or portals from your devices (including mobile devices) and applications; and
• Share Personal Data with third parties that are entitled to share that data, but in each case as permitted by applicable laws.

Where We Store Your Personal Data

The Personal Data that we collect from you will be transferred to and stored at destinations within Nigeria. By submitting your Personal Data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Policy. 

Do We use Cookies?

We use cookies to improve your browsing experience on our website. By browsing on our website, you consent to our use of cookies in accordance with our privacy policy.

About Cookies

Cookies are a kind of short-term memory for the web. They are stored in your browser and enable a site to ‘remember’ little bits of information between pages or visits. Cookies can be used by web servers to identify and track users as they navigate different pages on a website, and to identify users returning to a website. Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Our Website cookies

We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on Your device until you delete them). We need the cookies to enable technical performance of Our websites and allow us to ‘remember’ the choices you make and your preferences (Functionality) and to allow us collect certain information about how You navigate the Sites (Performance/Analytical).

By this, we are able to understand which parts of Our websites are interesting to You and which are not, as well as what We can do to improve them.

How We Use Cookies

Cookies do not contain any information that personally identifies You, but Personal Data that We store about You may be linked, by us, to the information stored in and obtained from cookies. The cookies used on Our website include those which are strictly necessary for access and navigation, cookies that track usage (performance cookies) and those used to remember your choices (functionality cookies). We may use the Personal Data We obtain from Your use of our cookies for the following purposes:

• To provide you with a better website experience by enabling us to monitor which pages You find useful and which you do not;
• To recognise Your computer and track you when You visit Our website;
• To retain investors’ email addresses and passwords when they log in to Our investment centre; and
• To analyse the use of Our website – such as how many people visit us each day.

Third-party Cookies

Our website uses cookies provided by trusted third-party such as Google Analytics, which is one of the most widespread and trusted analytics solutions on the web. This helps us to understand how You use the site and ways that We can improve Your experience.

Accepting, Declining and Disabling Cookies

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but You can usually modify your browser setting to decline cookies if you prefer. However, this may prevent you from taking full advantage of the website. You can also disable cookies if You wish. However, this will affect the functionality of Our website and many other websites that You visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore, it is recommended that you do not disable cookies.

Links to other websites

Our Site may contain links to other websites of interest. However, once You have used these links to leave Our Site, You should note that We do not have any control over such websites. Therefore, We cannot be responsible for the protection and privacy of any information which You provide whilst visiting such websites and such websites are not governed by this Privacy Policy. You should exercise caution and review the privacy statement(s) applicable to the websites.

Controlling your Personal Data

You may choose to restrict the collection or use of your Personal Data in the following ways:

• Whenever You are asked to fill in a form on the Site, the privacy policy link will be available. You can decide not to fill the form if you do not accept the terms of the policy;
• If You have previously agreed to us using Your Personal Data for direct marketing purposes, You may change Your mind at any time by emailing us at privacy@greenetro.com

We will not sell, distribute or lease Your Personal Data to third parties unless we have Your permission or are required by law to do so. We may use Your Personal Data to send You promotional information about third parties which We think You may find interesting subject to your written permission to do so.

How we protect your Personal Data

We are committed to ensuring that Your Personal Data information is secure. In order to prevent unauthorised access or disclosure, We have put in place reasonable physical, electronic and managerial procedures to safeguard and secure the Personal Data We collect online.

In particular, We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of Your personal transaction information and data stored on our Site.

Sensitive and private data exchange between the Site and its Users happens over a secured communication channel and is encrypted and protected. Transactions are also handled over a secure payment gateway. Also, Greenetro has implemented appropriate technical, physical and organisational measures designed to protect Personal Data against accidental or unlawful destruction, accidental loss, damage, alteration, unauthorised disclosure or access, as well as all other forms of unlawful processing.

Retention of your Personal Data

We maintain Personal Data not longer than we need to use it in accordance with Greenetro’s Data Retention Policy. In some circumstances, we may retain your Personal Data for longer periods if it is in accordance with regulatory, legal, tax or accounting obligations. Greenetro has an established retention procedure it applies to records and Personal Data collected and stored. In all cases, where your Personal Data is no longer required or you request for deletion, we will ensure it is disposed of in a secure manner.

Sharing your Personal Data

We do not sell, trade, or rent Users Personal Data to others. We may share generic aggregated demographic information not linked to any Personal Data regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We will not disclose Your Personal Data to anyone outside Greenetro without Your consent to do so unless one of the following circumstances applies:

1. With your consent

We will share Personal Data with companies, organizations or individuals outside of Greenetro when We have your consent to do so. We shall obtain your consent before sharing of any sensitive Personal Data.

2. Processing of Personal Data of minors

Where we collect the Personal Data of a minor, we shall obtain the consent of a parent or guardian and we shall ensure that the purpose of processing or collecting the Personal Data is clear to both the minor and the parent or guardian.

3. For external processing

We provide Personal Data to our affiliates or other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.

4. For legal reasons

We will share Personal Data with companies, organizations or individuals outside of Greenetro if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

• meet any applicable law, regulation, such as the Nigeria Data Protection Regulation (NDPR), legal process or enforceable governmental request.
• detect, prevent, or otherwise address fraud, security or technical issues.

protect against harm to the rights, property or safety of Greenetro, our Users or the public as required or permitted by law.

Your acceptance of these terms

By using this Site, You signify Your acceptance of this policy. If You do not agree to this policy, please do not use Our Site. Your continued use of the Site following the posting of changes to this policy will be deemed Your acceptance of those changes.

Accessing and updating your Personal Data

Whenever You use Our services, We aim to provide You with access to Your Personal Data. If that Personal Data is wrong, We strive to give You ways to update it quickly or to delete it – unless We have to keep that Personal Data for legitimate business or legal purposes. When updating Your Personal Data, We may ask You to verify Your identity before We can act on Your request.

We shall, at your request, can confirm what Personal Data We hold about You and how such Personal Data is processed. The following Personal Data are available upon Your request.

• Contact details of the Data Protection Officer, where applicable;
• The purpose of the processing as well as the legal basis for processing;
• The categories of Personal Data collected, stored and processed;
• Recipient(s) or categories of recipients that the data is/will be disclosed to;
• Information about how We ensure transfer of Personal Data to a third party or international organisation is done securely. The Attorney General of the Federation will approve sending Personal Data to some countries because they meet a minimum standard of data protection. In other cases, We will ensure there are specific measures in place to secure your information;
• How long the data will be stored;
• Details of Your rights to correct, erase, restrict or object to such processing;
• Information about Your right to withdraw consent at any time;
• How to lodge a complaint with the supervisory authority, National Information Technology Development Agency (NITDA);
• Whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the Personal Data and the possible consequences of failing to provide such data;
• The source of Personal Data if it was not collected directly from you; and
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

Your Rights as a Data Subject

At any point while we are in possession of or processing your Personal Data, You, the data subject, have the following rights:

• Right of Access – You have the right to request a copy of the information that We hold about you
• Right of Rectification – You have a right to correct data that We hold about You that is inaccurate or incomplete
• Right to be Erased/Forgotten – In certain circumstances You can ask for the data We hold about You to be erased from our records
• Right to Restriction of Processing – Where certain conditions apply to have a right to restrict the processing
• Right of Portability – You have the right to have the data We hold about you transferred to another organisation (to be reused for Your own purposes)
• Right to Object – You have the right to object to certain types of processing such as direct marketing
• Right to Object to automated processing, including profiling – You also have the right to be subject to the legal effects of automated processing or profiling
• Right to Withdraw – You have the right to withdraw Your consent at any time

Dispute Resolution or Filing A Complaint

If you have any complaints regarding our compliance with this Privacy Policy, please contact our Data Protection Officer. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information within thirty (30) days in accordance with this Privacy Policy and in accordance with applicable law and regulation.

Changes to this privacy policy

Our Privacy Policy may change from time to time. We will not reduce your rights under this Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes) or via a pop-up notice or statement of changes on our website)

You acknowledge and agree that it is Your responsibility to review this Policy periodically and become aware of modifications. This Privacy Notice or Policy was last updated on 20 June 2022. The most up-to-date version can be found on this website.

Compliance with the Regulations

This Privacy Policy is in line with the provisions of Nigeria Data Protection Regulation, 2019 (Regulation), a regulation which describes how organisations including Greenetro must collect, handle and store Personal Data and applies regardless of whether data is stored electronically, on paper or on other materials.

According to the Regulation, Greenetro shall notify NITDA within 72 hours of knowledge of a breach of security leading to accidental or unlawful destruction, loss, alteration unauthorized disclosure of, or access to your Personal Data.

If you feel that your Personal Data has not been handled correctly or you are unhappy with our response to any requests you have made to us regarding the use of your Personal Data, you have a right to lodge a complaint with the NITDA. The contact details are:

National Information Technology Development Agency

Tel: +234929220263, +2348168401851, +2347052420189

Email: info@nitda.gov.ng

Website: www.nitda.gov.ng

Contact Us

If you have any questions or suggestions regarding our privacy policy, please contact our Data Protection Officer.

Contact details of the Data Protection Officer:

Contact Name:   ‘Leke Dada

Email:                 privacy@greenetro.com

Telephone:        + 234 (0) 816 582 3474